UNITED STATES v. ESTATE OF DONNELLY

No. 104.

397 U.S. 286 (1970)

UNITED STATES v. ESTATE OF DONNELLY ET AL.

Supreme Court of United States.

Decided March 23, 1970


Attorney(s) appearing for the Case

Matthew J. Zinn argued the cause for the United States. On the brief were Solicitor General Griswold, Assistant Attorney General Walters, Joseph J. Connolly, and Crombie J. D. Garrett.

Daniel N. Pevos argued the cause and filed a brief for respondents.


MR. JUSTICE MARSHALL delivered the opinion of the Court.

In 1950, a tax liability of approximately $26,000 was assessed against the taxpayer Donnelly, a resident of Michigan. Upon assessment, a statutory lien was created in favor of the United States "upon all property and rights to property, whether real or personal" belonging to the taxpayer. Internal Revenue Code of 1939, § 3670. Under § 3672 of the 1939 Code, such a lien could become effective against...

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